555 U.S. 271 (2009)
Crawford v. Metropolitan Government of Nashville and Davidson County, Tennessee is a foundational Title VII retaliation case that clarified the scope of protected activity under the statute's opposition clause.
Does Title VII's anti-retaliation opposition clause protect an employee who reports workplace harassment by answering an employer's questions during an internal investigation, even though the employee did not initiate a complaint or external charge?
Title VII's anti-retaliation provision, 42 U.S.C. § 2000e-3(a), makes it unlawful for an employer to discriminate against an employee because the employee has opposed any practice made unlawful by Title VII (the opposition clause), or because the employee has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under Title VII (the participation clause). An employee engages in protected opposition when she communicates to her employer a belief that the employer has engaged in a form of employment discrimination proscribed by Title VII, and this protection extends to statements made in response to employer-initiated questioning during an internal investigation, so long as the employee has an objectively reasonable, good-faith belief that the conduct opposed violates Title VII.
Yes. An employee's disclosure of discriminatory conduct in response to questions during her employer's internal investigation is protected opposition under Title VII's anti-retaliation provision. The Sixth Circuit's judgment was reversed and the case remanded.
Crawford resolves a once-contentious question by squarely protecting employees who report discrimination in internal, employer-initiated investigations. It harmonizes Title VII's anti-retaliation protections with internal compliance programs, reducing the risk that employees will shun internal channels. Post-Crawford, employers must treat internal witnesses and complainants as engaging in protected activity, adjust policies and training accordingly, and carefully document legitimate, non-retaliatory reasons for any subsequent adverse actions. For students, Crawford illustrates textual interpretation grounded in ordinary meaning, interaction between the opposition and participation clauses, and the Supreme Court's sensitivity to Title VII's policy goals. It also underscores that retaliation claims involve multiple elements: protected activity, materially adverse action, and causation. Crawford primarily addresses the first element and leaves the remaining questions of pretext and causation to be resolved on remand or at trial.